- 32 - There are other sections, however, where the word “remaining” is used in a different context as a copula12 or linking verb. When used as a copula the word “remaining” links the word that precedes it to the word that follows it;13 e.g., the income remaining undistributed. In those sections, the word “remaining” means that the preceding word “continues to be unchanged” in the “form, condition, or status” described by the word that follows. We believe that within the context of the effective date provisions of section 6015 a tax liability “remaining unpaid” on or after July 22, 1998, means that the liability continues to be unpaid after July 22, 1998. The applicability of section 6015 to the issue before us thus turns on the meaning of the word “unpaid”. The primary definition 11(...continued) application of subsection (a)”); sec. 7608(c)(3) (“such proceeds or the balance of such proceeds remaining at the time”); sec. 9008(f) (“moneys remaining in the account * * * moneys so remaining”); sec. 9038(b)(3) (“that portion of any unexpended balance remaining in the candidate’s accounts”). 12 Copulas are verbs that link a predicate (adjective, noun, etc.) to the subject. I Curme, A Grammar of the English Language, par. 12.3, 66 (1986). Copulas often indicate a state, continuance in a state, or entrance into a state. Id. par. 12.3, 68. The verb “remain” is among the most common copulas and indicates a continuance in a state. II Curme, A Grammar of the English Language, par. 6.B, 27-28. 13 See, e.g., sec. 411(b)(1)(A) (“benefits * * * shall be treated as remaining constant”); sec. 9704(i)(1)(B) (“the expenses accrued (and remaining unpaid)”); sec. 4942(a) (“the amount of such income remaining undistributed at the beginning of such second (or succeeding) taxable year”); sec. 7448(j)(3) (“Any accrued annuity remaining unpaid”).Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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